Suggested Answer:Explanation🗳️
Access or covered persons have knowledge of pending or actual investment recommendations or action. The firm's definition of access (covered) person should be broad enough to cover all people with that knowledge.
based on SEC doc: Covered Persons
A Covered Person under the Code includes any employee holding the position
of Vice President or higher, all Cornerstone analysts and any other employee
notified by the Chief Compliance Officer ("CCO") that he or she is a Covered
Person. "Covered Person" as referred to in this Code has been defined to include
those persons defined in the Rules as "Access Person(s)".
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KAla7223
1 year, 11 months ago